The Immigration Salary List is due to close on 31 December 2026, bringing changes for healthcare employers that use sponsorship to recruit or retain staff in certain roles. The change is particularly relevant to some roles below degree level that currently rely on the list, including nursing auxiliaries and assistants, pharmaceutical technicians, and laboratory technicians in roles requiring at least three years’ related on-the-job experience. However, the position will not be the same for every sponsored worker because the skill level of the role and the date on which the first Certificate of Sponsorship was assigned both matter. This makes the closure more than a future recruitment issue. Employers may also need to understand what it could mean for people already within their workforce.
NHS Employers states that transitional arrangements apply to workers first sponsored in affected RQF level 3 to 5 roles before 22 July 2025. Those first sponsored before that date can continue to apply for extensions, changes of employment and settlement under the current position. Workers first sponsored in affected roles on or after 22 July 2025 can extend their permission or change employment while the Immigration Salary List remains in place, but will no longer be able to do so in those roles once the list closes. NHS Employers also says that workers sponsored in RQF level 6 roles on the list can continue to apply for extensions, changes of employment and settlement, regardless of when they were first sponsored.
A particularly important detail is that the relevant date is when the Certificate of Sponsorship was assigned, rather than when the visa application was submitted or granted. Two people working in similar roles may therefore be in different positions. Employers should also verify the correct occupation code rather than relying on a general job title, as eligibility depends on how the role is classified under the current rules.
Understanding the existing workforce
The immediate workforce question is whether employers have a clear and current record of sponsored staff in potentially affected roles. This does not mean making assumptions about an individual’s future immigration status, as that depends on the rules and circumstances applicable to that person and may require specialist advice. At organisational level, however, employers can establish which roles currently rely on Immigration Salary List eligibility, when the relevant Certificates of Sponsorship were assigned and where future recruitment plans assume that the same eligibility will remain available.
The closure may also affect new recruitment. NHS Employers states that once the list closes, it will no longer be possible to assign a new Certificate of Sponsorship for roles that depend on Immigration Salary List eligibility. It also says that new applications and in-country switches into those roles will no longer be possible after the closure, although a visa application may still be submitted after that date where a valid Certificate of Sponsorship was assigned beforehand.
This creates a practical planning issue. A role that can currently be sponsored through Immigration Salary List eligibility should not automatically be treated as available on the same basis in 2027. Recruitment teams, workforce leaders and those responsible for sponsorship need a shared understanding of which roles are affected, which dates are relevant and where planned recruitment may depend on eligibility that is due to change.
Planning with information that may still change
The position is not completely settled. NHS Employers notes that the arrangements remain subject to future changes to the Immigration Rules, including proposals relating to earned settlement. It also reported on 1 October 2026 that no additional Home Office guidance had been published at that point. Employers should therefore avoid treating the current information as a final account of every future scenario. The sensible approach is to work from the rules and guidance currently in force, record any areas of uncertainty and recheck the official position before making decisions.
Care is also needed when communicating with sponsored staff. General workforce information should not be presented as a conclusion about an individual’s right to remain, extend a visa, change employment or qualify for settlement. Anyone potentially affected may need advice based on their own circumstances from an appropriately qualified immigration professional.
The wider workforce point is that sponsorship planning cannot sit separately from recruitment and retention planning. Employers need to understand which existing roles may be affected and whether their future hiring plans rely on eligibility that is due to change.
The Immigration Salary List does not close until 31 December 2026, but organisations may already hold much of the information needed across workforce records, occupation codes and sponsorship dates. Organisations that map this now are likely to be in a stronger position as the rules develop and future recruitment decisions need to be made.